The case, in numbers
The leak
When a community bank sells the guaranteed portion of an SBA 7(a) loan, the premium it may keep is capped at 110 — half of anything above goes back to SBA. A strip of about 1.00% a year leaves with the sale. Pools of guaranteed loans — the institutional-grade product — require at least four loans and $1 million of guaranteed principal, a threshold a bank making a handful of loans a year cannot reach, so it takes an outside broker's bid or doesn't sell at all. And it keeps, always: the unguaranteed slice, all of the servicing, and all of the risk that the guaranty will be repaired or denied.
The Bureau of Indian Affairs loan guaranty program — the one written for Indian Country, up to 90% guaranteed, with a $1.5 billion statutory cap — has no secondary market at all. It typically guarantees 22 to 35 loans a year.
The fix
A Guarantee Desk, operated inside a bank services corporation owned by the member banks themselves under the Bank Service Company Act (12 U.S.C. §§ 1861–1867): aggregated execution and pool assembly, institutional-grade program administration, and a guaranty-defense quality-control function on every file — with servicing that never leaves the originating bank. Because the costs are shared, the same company carries the highly technical compliance services — BSA/AML, examination evidence, Opportunity Zone reporting — that no small bank can staff alone.
According to the research record behind this program, no such member-owned wholesale layer has ever been built for America's tribal and Black-owned banks. A sister company opens partnership participation to tribal governments, CDFIs, and credit unions, and a bankers' bank charter (12 U.S.C. § 27(b)) is the later stage, when volume earns it.
The roadmap
Roll-up investment packages of government-guaranteed paper for insurance companies and other institutional investors. Treasury products built for the buyers who now hold government securities at the largest scale — including stablecoin companies. Real-world-asset tokenization inside the regulated perimeter. Custody with two-of-three multi-signature control. Each stage gated on the law and the licenses it requires — stages, not promises.
The coalition
Founding recruitment starts where the banks and the need already coincide: eastern Oklahoma (ten of the twenty Native MDIs), Robeson County, North Carolina, and the Michigan corridor (Detroit to the Upper Peninsula). A consortium Academy — mentorship for the desk's craft, and self-paced online education across all areas of banking — trains the workforce from the communities served.
This page presents a planning program and published research. It is not an offer of securities, not investment advice, and not a solicitation. Figures are drawn from FDIC, Federal Reserve, NCUA, CDFI Fund, SBA, and GAO sources as dated in the program's research, October 2026.